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Aronson v. North Park College





APPEAL from the Circuit Court of Cook County; the Hon. CHARLES E. FREEMAN, Judge, presiding.


Rehearing denied April 13, 1981.

Lillian Aronson (plaintiff) brought this action against defendant North Park College (or NPC), a private school, as a result of her dismissal as a student. After a bench trial, plaintiff was awarded damages of $22,321.60. Defendant appeals and plaintiff seeks an increase in damages by cross-appeal.

Plaintiff originally filed a complaint against defendant and other named persons in the United States District Court for the Northern District of Illinois. That action alleged a violation of plaintiff's civil rights as a result of her dismissal from NPC. The case was dismissed because plaintiff's attorney failed to appear for a status report. The court of appeals affirmed the dismissal.

Plaintiff filed a second suit in Federal District Court again alleging a violation of her civil rights and also a violation of the oral contract between the parties. An order was entered based upon res judicata granting defendant's motion to dismiss "all claims except those relating to the breach of contract claim." Thereafter, an order was entered dismissing the breach of contract claim for lack of Federal jurisdiction. Plaintiff appealed to the court of appeals, but subsequently dismissed this appeal on her own motion.

On January 8, 1975, plaintiff filed the instant action in the circuit court. Her amended complaint was also based on plaintiff's dismissal from NPC in 1967. Count I alleged a breach of contract. Count II alleged a violation of plaintiff's constitutional rights. Count III alleged an arbitrary and a negligent violation of her right to privacy. The trial court dismissed count II on the basis of res judicata and count III as being barred by the statute of limitations. The trial proceeded only on the breach of contract claim as alleged in count I.

The evidence shows that on January 25, 1966, plaintiff applied to NPC for admission as a student. She was accepted and completed one evening course in the spring and another in the summer of 1966. That fall, she enrolled as a full-time student.

In November 1966, plaintiff received a notice from the dean of students to take the Minnesota Multiphasic Personality Inventory Test (MMPI). This test was developed by the University of Minnesota and consists of 566 objective questions. There is evidence that this test is a well-regarded psychological examination and that all incoming students were required to take it. As a result of their scores, some students were referred to the Covenant Counseling Center (counseling center) for a review of their test score. On the basis of this review, the counseling center would decide if further counseling was necessary. Plaintiff testified she received no information about psychological testing before her fall enrollment.

Plaintiff subsequently took the test, which was graded at the University of Minnesota. Pursuant to standard procedure, the counseling center staff reviewed plaintiff's score. Because her results showed a deviation from normal, the center notified NPC. In February 1967, plaintiff received a notice to go to the counseling center for interpretation of her score. She did not appear for her scheduled appointment. The dean of students, Carroll J. Peterson, sent plaintiff a letter requesting her to appear at the center or face dismissal. In a telephone conversation, Dean Peterson told plaintiff she would be obliged to appear at the center several times and this procedure was required of 5 to 10 percent of all NPC students.

On February 21, 1967, plaintiff had a 30-minute interview with William O. Hunt, a student psychologist at the counseling center. During this interview she was given another personality test. Plaintiff returned to the counseling center on March 28, 1967, to fill out a biographical questionnaire. When asked when she would return, plaintiff sought out Mr. Hunt, protested, and departed. Mr. Hunt subsequently prepared a report dated March 28, 1967, describing plaintiff as "frightened and running" or "slightly below average in intelligence" and with symptoms of "blocking" and "denial."

Plaintiff returned to the counseling center on May 9, 1967, for a brief interview with Dr. Richard Cox, a clinical psychologist. On May 11, Dean Peterson received the following memorandum from Dr. Cox concerning plaintiff:

"The above named student was seen as a result of MMPI deviations. Further interviews reveal a pronounced, chronic paranoid condition which will be a serious detriment to herself and others. This is particularly serious inasmuch as she plans to enter the field of education. She is totally unaware of her condition, unwilling to involve herself in treatment and therefore at this time renders herself untreatable. This student does not possess sufficiently strong mental health to continue the pursuits of college or an educational career at this time."

On the basis of this memorandum, Dean Peterson wrote plaintiff a letter informing her of her dismissal from NPC at the end of the term due to her lack of "sufficiently strong mental health."

A meeting of the counseling center staff was held on May 16, 1967. Dr. Truman Esau, the staff psychiatrist, attended. The staff as a whole diagnosed plaintiff as being in a "paranoid state."

Between July 1967 and June 1968 plaintiff had several contacts with Dean Peterson and other NPC officials concerning readmission. She requested the school to contact her then current psychiatric therapist. On June 19, 1968, Dean Peterson refused plaintiff's request for readmission due to her mental status. Subsequently, on July 9, 1968, Dean Peterson received the following memorandum from Dr. Esau:

"This will confirm that I have had a contact from Dr. Francis Parks who is the therapist of Lillian Aronson. It is my understanding from my conversation that the patient's personality characteristics are unaltered. Any behavioral ...

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